Finding Text
Assistance Listing Number: 93.958
Name of Federal Program: Block Grants for Community Mental Health Services
Name of Federal Agency: Department of Health and Human Services
Name of Pass-through Entities and Award Periods: Wisconsin Department of Health Services – October 1, 2021 through September 30, 2022, April 1, 2022 through September 30, 2022, October 1, 2022 through September 30, 2023, Milwaukee County Behavioral Health Division – January 1, 2022 through December 31, 2022, and Milwaukee County Department of Health Services – January 1, 2022 through December 31, 2022
Criteria or Specific Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)).
Condition: During our testing of reimbursement requests, we identified an invoice that included expenses outside the period of performance for a grant in the federal program.
Cause: Sufficient internal controls for reimbursement requests have not been implemented to ensure costs included for reimbursement are within the period of performance.
Effect or Potential Effect: An expense charged to the federal program could be disallowed.
Questioned Costs: $48,728.
Context: This appeared to be an isolated incident from one grant invoice that was tested during audit procedures performed on financial statement account balances. For testing period of performance requirements, we selected a sample of 20 expense transactions and did not identify any expenses charged to grants outside the period of performance.
Repeat Finding: No
Recommendation: Additional internal controls for reimbursement requests should be implemented, including having another individual outside the process review and approve reimbursement requests prior to submission or require detailed accounting expense transactions be included with reimbursement requests to ensure expenses have been incurred within the period of performance.
Views of Responsible Officials: Management agrees with the finding and the Organization and outsourced accounting rep will meet monthly to review cost reports and correlating invoices together before approving and submitting to the funder to ensure expenses submitted are within the grant performance period.